GHG Phase 2 explained

A new set of commercial vehicle design standards meant to reduce the industry’s greenhouse gas production could cause a divide between the United States’ leading trailer OEMs – if it can find a way past a climate change-critical new administration.

When Barack Obama was first elected President of the United States (POTUS) in 2008, he openly stated that addressing climate change was one of his core objectives. At the time, heavy-duty vehicles accounted for some 20 per cent of greenhouse gas (GHG) emissions and oil use in the US transportation industry, so they quickly became a focal point of the President’s sustainability agenda.

But while the Government moved quickly to set new emissions standards for medium- and heavy-duty trucks, it gave creative control on how to achieve the desired results up to the industry: “We let the automakers decide how they were going to do it,” Obama recently recalled in looking at his tenure as POTUS. “We set the goal and we said, go figure it out, and they invested in innovative and cost-effective technologies.”

The initial set of GHG regulations – focusing primarily on motorised equipment – outlined fuel consumption reductions through to 2018, but the climate-conscious President was only getting started. As part of his 2014 Climate Action Plan, Obama called on the country’s Environmental Protection Agency (EPA) to develop new, even more comprehensive standards that would run all the way into the next decade.

First proposed in July 2015 and finalised in August 2016, the resulting GHG Phase 2 regulations now set sustainability-related design standards for medium- and heavy-duty vehicles through to model year 2027. Jointly developed by the EPA and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA), they are considered just ambitious as they are controversial.

Under Phase 2, the agencies expect newer, advanced technologies that are currently not mandated to be used as standard. “The final standards are expected to lower CO2 emissions by approximately 1.1 billion metric tonnes, save vehicle owners fuel costs of about US$170 billion, and reduce oil consumption by up to two billion barrels over the lifetime of the vehicles sold under the program,” they outline in the 1,700-page-strong document.

To do so, semi-trailers are now held just as accountable for the reduction of greenhouse gas emissions as trucks – a first in the history of commercial road transport. Some trailer standards are coming into effect next year, followed by more stringent regulations in 2021, 2024 and finally in 2027, by which time the trailer is expected to help reduce emissions between three and nine per cent depending on the type of construction.

The agencies are especially focused on the use of aerodynamic shielding like side skirts and so-called boat tails, but also recommend the use of low rolling resistance tyres, saying trailer OEMs are expected to implement “incrementally greater improvements” as standard stringency increases through to 2024.

Reactions by trailer OEMs toward the legislation have since been mixed, with two of the nation’s largest manufacturers seemingly representing either end of the spectrum: On the one side, Wabash National came out in favour of the new regulations, stating all trailer builders should comply as long as the final rule is “consistent with overlapping government policies to promote technological advancements and innovation in the trailer manufacturing industry”.

North America’s largest OEM quickly reaffirmed its supportive stance by taking part in the Government-funded SuperTruck project – a design challenge with the goal of showcasing just how far the envelope could be pushed from a technology perspective. According to Wabash National, the company’s main objective was to maximise aerodynamic performance, with the resulting unit’s drag coefficient having been reduced by more than 30 per cent over a standard model.

“On the heels of the GHG2 rule being finalised, the industry will need to innovate in order to meet fuel efficiency standards in the future,” says Brian Bauman, Vice President and General Manager at Wabash Composite, a composite panel specialist that is part of the Wabash National Corporation. He adds the SuperTruck design is not only aerodynamic, but also lightweight, with the Wabash National team managing to shave more than 2,000 pounds (ca. 907kg) off a comparable 2009 dry van model.

On the other side of the GHG2 regulations debate stands Californian OEM, Utility Trailer. The company publically questioned the agencies’ right to set targets for articulated trailers when the new legislation was unveiled, saying they had adopted an “unprecedented interpretation of their authority” that exceeded their Congressional authorisation.

“Additionally, the agencies have based their analysis on assumptions that are completely untethered from the real world, resulting in proposed regulations that will yield minimal, if any, net greenhouse-gas reductions while imposing crippling administrative burdens on the semi-trailer industry,” Utility said in a 2016 statement.

Utility Trailer’s resistance to the new regulations doesn’t mean that it is generally against the use of aerodynamic devices to reduce fuel consumption, though. In fact, the company is one of the few manufacturers in the US that design, develop and manufacture their own brand of trailer tail in-house. However, it’s the second and third levels of the regulations that the OEM is concerned about.

“[Reducing fuel consumption is] going to get increasing more difficult and challenging to achieve,” Craig Bennett, the brand’s Senior Vice President of Sales and Marketing, recently told local US news outlet, Heavy Duty Trucking. “When it comes to 2024 and 2027, we have no idea yet how to achieve it. And there is no one in the industry right now who knows how to achieve those fuel economy results.”

Part of the answer could lie in so-called ‘lightweighting according to the Department of Energy (DoE). With data suggesting that a 10 per cent reduction in vehicle weight can result in fuel economy improvements of up to eight per cent, the Department has challenged OEMs to replace cast iron and traditional steel components with lightweight materials such as high-strength steel, magnesium alloys, aluminium alloys, carbon fibre and polymer composites. These materials can reportedly reduce the weight of a vehicle’s body and chassis by up to 50 per cent and therefore positively affect fuel consumption in the required magnitude.

Utility Trailer wasn’t alone in its opposition to the ruling, though: Right on the deadline to file official legal complaints in December last year, the Truck Trailer Manufacturers Association (TTMA) submitted a petition to remove trailers from the standards altogether, claiming the additional weight of aerodynamic devices would effectively counteract the desired fuel savings.

The complaint is currently being reviewed and will force the new US administration, which came into office in January, to either defend or alter the regulations before they officially take effect. Environmentalists across the US are thus concerned that the climate change-critical Trump Government could still overrule the entire directive – and rightly so.

In early February, the Senate approved of the appointment of Trump confidant and Oklahoma Attorney General, Scott Pruitt, as the new EPA Administrator. The appointment has since been widely criticised, with a letter of discontent submitted by no less than 443 EPA Veterans pointing out the irony of Pruitt running an agency that he has personally sued “more than a dozen times”.

“Pruitt’s record and public statements strongly suggest that he does not share the vision or agree with the underlying principles of our environmental laws,” the letter says – pointing out that Pruitt has openly celebrated lawsuits against the Agency in more than 50 press releases.

At the time of print*, the trailer standards as set in the Regulations for Greenhouse Gas Emissions from Commercial Trucks & Buses Phase 2 are still to be implemented as planned. But while Wabash opted to continue working on its SuperTruck project, Utility said it would ‘wait and see’ what the controversial President will do next. The Trump administration is yet to make an official announcement on the ruling, leaving the future of the emissions regulations – at least as envisioned by Barack Obama – up in the air.

What you need to know

If approved by the new administration, the new GHG2 regulations will differentiate four categories of heavy-duty vehicles and related equipment – combination trucks or prime movers, trailers used in combination with those trucks, heavy-duty pick-up trucks and vans, as well as vocational vehicles.
The most significant new addition to the line-up is the ‘trailers hauled by heavy-duty trucks’ category, which is not included in the current Phase 1 rule. The affected vehicles, mainly dry and refrigerated vans with a length over 50 feet (15.2m), will have to use gap reducers, trailer skirts, boat tail devices and other aerodynamic devices to achieve gradually increasing levels of fuel and CO2 savings. Units below 50 feet in length may be able to avoid some requirements depending on length and design. Here, the EPA and NHTSA differentiate between a full, partial, and non-aero designation.
Vocational-type or ‘non-box’ trailers – such as flat beds, tankers or container chassis – are expected to have to use automatic tyre pressure management devices and low rolling resistance tyres only, with the so-called Tyre Rolling Resistance Level (TRRL) set to be reduced gradually over time.
Trailers with work-performing equipment (WPE) fitted at the rear or side – for example a tailgate or side steps for side-door access – also don’t need to meet all the criteria for aerodynamic improvement, but could have to comply with some.
The GHG2 program will begin for regulated trailer types manufactured on or after 1 January 2018, with a one-year delay for trailer manufacturers that qualify as small businesses.